Justia Maine Supreme Court Opinion Summaries

Tammy and James Rutledge filed a lawsuit against Pamela Menard and Randall Nappi, seeking to recover personal property. The Rutledges followed the instructions on Form CV-218, which was available on the Maine Judicial Branch's website, to serve the defendants. This form was created during the COVID-19 pandemic and instructed plaintiffs to prepare for a telephonic status conference as the first court event. However, by the time the Rutledges filed their lawsuit, the Maine Supreme Judicial Court had rescinded most of the pandemic management orders, and court proceedings had returned to an in-person format.The District Court (Bridgton, Malia, J.) dismissed the Rutledges' complaint with prejudice due to their failure to appear in person for a hearing. The Rutledges had mistakenly believed that the initial court proceeding would be a telephonic status conference, as per the instructions on Form CV-218. They appealed the decision, arguing that the court erred in dismissing their case with prejudice and denying their post-judgment motion to reopen the case or amend the judgment to a dismissal without prejudice.The Maine Supreme Judicial Court found that the District Court did not err in finding that the Rutledges failed to appear. However, it held that the dismissal with prejudice was too drastic a sanction given the circumstances. The court noted that the Judicial Branch's website continued to direct parties to Form CV-218, which no longer reflected current court practices, contributing to the Rutledges' mistaken belief. The court also noted that the Rutledges' nonappearance was neither deliberate nor the result of misconduct, and they made a sustained effort to remedy their error. The court vacated the judgment and remanded the case to the District Court for entry of a judgment of dismissal without prejudice. View "Rutledge v. Menard" on Justia Law

Jamie Pacheco filed a divorce case against her then-husband, Kevin Pacheco, in 2015. She was represented by Jeffrey Bennett, Esq., and his firm, Legal-Ease, LLC, P.A. During the divorce proceedings, Bennett voluntarily produced to Kevin's counsel, Libby, O’Brien, Kingsley, and Champion, LLC, the complete counseling session notes of Jamie’s therapist, Sandra Falsey, with one redacted line. Libby later subpoenaed Falsey without notifying Bennett and obtained her complete counseling records related to Jamie, including the unredacted therapy notes. After the divorce proceedings concluded, Jamie, still represented by Bennett, filed an action against Libby asserting claims of abuse of process, intentional infliction of emotional distress (IIED), and negligent infliction of emotional distress (NIED) based on Libby obtaining Falsey’s unredacted therapy notes and disclosing them to Kevin.The Superior Court (Androscoggin County, Stewart, J.) had previously granted a motion to dismiss Jamie’s tort complaint. However, the Maine Supreme Judicial Court partially vacated the dismissal, leaving Jamie’s claims of abuse of process and IIED in dispute. Later, Libby filed a motion to disqualify Bennett, asserting that Bennett’s continued representation of Jamie would violate Maine Rule of Professional Conduct 3.7 and prejudice Libby. The Superior Court granted Libby’s motion, finding that Bennett is likely to be a necessary witness on several topics related to the case.On appeal, the Maine Supreme Judicial Court affirmed the lower court's decision. The court found that Bennett's actions or inactions in the treatment and disclosure of Jamie’s psychotherapy records were central to Jamie’s case, and Bennett alone had this knowledge, making his testimony relevant, material, and unobtainable from other sources. The court also found that there were sound bases in the record for the lower court’s conclusion that there would be actual prejudice in allowing Bennett to continue representing Jamie. View "Pacheco v. Libby, O'Brien, Kingsley and Champion, LLC" on Justia Law

The case involves Dennis G. Crosen, a former employee of Blouin Motors, Inc., who suffered two work-related injuries in 1984 and 2002, respectively. The 1984 injury occurred while Crosen was working for Rockingham Electric, Inc., and the 2002 injury occurred while he was working for Blouin Motors, Inc. The two injuries combined to render Crosen totally incapacitated. A hearing officer apportioned 40% of the responsibility for Crosen's incapacity to Rockingham and 60% to Blouin. In 2014, Crosen began collecting old-age insurance benefits under the United States Social Security Act. By statute, Blouin's obligation to pay weekly incapacity benefits based on the 2002 injury was to be reduced by half of the amount of Social Security benefits that Crosen receives. No Social Security offset applies to the compensation that Rockingham owes for the 1984 injury.The Administrative Law Judge (ALJ) and the Workers’ Compensation Board Appellate Division denied Blouin's petition to apply the entire Social Security offset to its compensation payments to Crosen. The ALJ and the Appellate Division interpreted the relevant statute to mean that Blouin could only apply the offset to the portion of the benefits for which it was responsible (60%), not the entire amount.The Maine Supreme Judicial Court disagreed with the lower courts' interpretation of the statute. The court held that Blouin was entitled to take the full offset provided by the statute, not just the portion corresponding to its share of responsibility for Crosen's incapacity. The court vacated the decision of the Appellate Division and remanded the case for further proceedings. The court also noted that Blouin may be entitled to a credit for the portion of the offset that it did not take prior to this case, but left this issue to be resolved on remand. View "Crosen v. Blouin Motors., Inc." on Justia Law

The case revolves around Jessica A. Williams, who was convicted for depraved indifference murder of her son, Maddox Williams. Maddox was born to Jessica and his father in 2018, and lived with Jessica after his father's arrest in 2020. From October to December 2020, Maddox occasionally had bruises on his body when he came from Jessica's care. In March 2021, Jessica assumed sole custody of Maddox. During her custody, Maddox had multiple injuries, which Jessica attributed to his clumsiness. In June 2021, Maddox was taken to the hospital where he lost consciousness and was pronounced dead. Jessica did not appear to react strongly to Maddox’s death and left the ER shortly after his death. She was later arrested by the police.The trial court had previously heard the case, where the State sought to introduce evidence of prior bad acts by Jessica. Over Jessica's objection, the court granted the motion. At the close of the evidence, Jessica moved for a judgment of acquittal, which the court denied. The jury subsequently returned a verdict of guilty and Jessica was sentenced to forty-seven years in the Department of Corrections.In the Maine Supreme Judicial Court, Jessica appealed her conviction, arguing that the trial court erred in admitting evidence related to a prior bad act, admitting evidence regarding her lack of communication with police officers, and denying her motion for a judgment of acquittal. She also argued that the cumulative effect of all three issues constituted a violation of her due process rights. The court disagreed with her contentions and affirmed the judgment. View "State v. Williams" on Justia Law

The case involves a dispute between Peter M. Beckerman and Ricky and Monica Conant over a deeded right-of-way over the Conants' driveway. The parties own abutting waterfront properties in Rome, Maine. Beckerman's property, the Conant property, and a third property, formerly known as the Bruce Pooler lot, are connected to South Crane Lane by a horseshoe-shaped driveway that runs across all three properties. Beckerman has a deeded right-of-way over the Conants' driveway to access South Crane Lane.Previously, Beckerman had filed an action against the Poolers, previous owners of the other two lots, to establish the location of the common boundaries of the three lots. The parties settled the action at mediation, resulting in a consent order in 2002 that established the current boundaries of the three properties. As part of the settlement, Beckerman secured a right-of-way over the driveway on the Bruce Pooler lot in order to access South Crane Lane.In 2012, Beckerman filed a post-judgment motion for contempt, alleging that the Conants were in contempt of the 2002 consent judgment by impeding his use of the right-of-way over the Conant lot. The court denied Beckerman’s motion for contempt because the language of the consent order was ambiguous. Beckerman appealed and the court affirmed the denial of the contempt but vacated the portion of the court’s determination regarding whether Beckerman had an easement by deed.On remand, after a three-day bench trial, the court entered a judgment declaring that Beckerman has a deeded right-of-way over the Conants’ driveway and enjoining the Conants from interfering with that right-of-way. The Conants appealed the judgment.The Maine Supreme Judicial Court affirmed the judgment. The court found that the language of the 2016 judgment was clear and specific, and the Superior Court did not abuse its discretion in finding the Conants in contempt. The court also found that the Superior Court did not err in concluding that Beckerman may use the entire paved driveway as needed to access his property. The court further held that the doctrine of claim preclusion did not apply in this instance as there was no valid final judgment entered with respect to Beckerman’s August 2016 motion for contempt. Lastly, the court held that the Superior Court was within its discretion to award Beckerman attorney fees under M.R. Civ. P. 66(d)(3)(C). View "Beckerman v. Conant" on Justia Law

The case involves Jaquille J. Coleman, who was convicted for murder and sentenced to forty-seven years in prison. The key facts of the case revolve around the murder of Natasha Morgan, Coleman's former partner and mother of his child. After their relationship ended, Coleman pursued Morgan, leading to an incident where he shot her in front of her mother. The police found bullets and shell casings at the scene and in the car Coleman had been driving, which were confirmed to have been fired from the same gun. Coleman was later found in Mississippi and extradited to Maine.Prior to the Supreme Judicial Court of Maine, Coleman had been convicted by the trial court after a jury trial. He appealed his conviction and sentence, arguing that the trial court had erred in admitting evidence of the victim’s state of mind, denying his motion for a mistrial based on a prosecutorial comment, and considering his failure to express remorse as an aggravating factor in his sentencing.The Supreme Judicial Court of Maine affirmed the lower court's decision. The court rejected Coleman's arguments, ruling that the evidence of the victim’s state of mind was admissible as it was relevant to show Coleman’s motive. The court also found that the prosecutor's comment did not shift the burden of proof to Coleman, and the court's immediate instruction to the jury clarified the burden of proof. Lastly, the court held that the sentencing court properly considered the substance of Coleman’s allocution in assessing lack of remorse as an aggravating factor. View "State v. Coleman" on Justia Law

This case involves a dispute over an easement, a right to cross or otherwise use someone else's land for a specified purpose. The plaintiffs, Kinderhaus North LLC, Prime Properties ME LLC, and Karen and Brian Fullerton (collectively, the Fullertons), own four lots in a subdivision and have an expressly deeded easement across a lot owned by the defendants, Karl and Stephanie Nicolas. The Fullertons claimed that the Nicolases had obstructed their easement by installing a granite lamp post and several trees. The Fullertons removed some of these trees, leading to a dispute over whether they had the right to do so and whether they had committed a timber trespass by cutting down the trees.The Business and Consumer Docket found that the Fullertons had an expressly deeded easement across the Nicolases' property, but that the easement was ambiguous as to its scope and purpose. The court found that the Fullertons did not have an unlimited right to use the full length and width of the easement as a driveway, and that the trees and lamp post did not prevent vehicle or pedestrian passage within the easement. The court also found that Karen Fullerton had committed a timber trespass by intentionally cutting down four trees within the easement, and awarded the Nicolases damages for this trespass. The court further found that Karen Fullerton had committed a common law trespass by entering the Nicolases' property without their consent, and awarded nominal and punitive damages for this trespass. The court granted summary judgment for the Nicolases on the Fullertons' slander of title and abuse of process claims.The Fullertons appealed, and the Maine Supreme Judicial Court vacated the lower court's judgment on several issues and remanded for further findings. The court held that the Fullertons had the right to remove obstacles within their easement, and that Karen Fullerton was therefore an "owner" within the meaning of the timber trespass statute. The court also held that punitive damages may be awarded in common law trespass cases where nominal damages are awarded, but remanded for the lower court to make further findings under the guidelines established by the U.S. Supreme Court for determining punitive damages. The court affirmed the lower court's judgment in all other respects. View "Kinderhaus North LLC v. Nicols" on Justia Law

The case involves Richard Peters, who was convicted for hunting a deer after having killed one and unlawful possession of wild animals. Peters appealed his conviction, challenging the denial of his motions for a mistrial, the sufficiency of the State’s bill of particulars, and the jury instructions. He also argued that double jeopardy protections barred his conviction on the charge of unlawful possession of wild animals.Previously, the trial court had stayed Peters’s sentence to require him to report to the Androscoggin County Sheriff’s alternative sentencing program. However, after Peters appealed, the court amended the stay to require him to surrender to the Penobscot County Sheriff to serve his sentence, interpreting M.R.U. Crim. P. 38(d) strictly.The Maine Supreme Judicial Court disagreed with Peters's contentions and affirmed the judgment. However, the court agreed with Peters that the trial court retained the authority to order the original stay and remanded the case for the trial court to consider whether to reinstate it. The court clarified that the trial court, having determined that the alternative sentencing program was appropriate, retained the discretion to order a stay to effectuate that determination. View "State of Maine v. Peters" on Justia Law

This case involves a dispute over a contract zone agreement that would have allowed development on a property in Saco, Maine. The property owners, Amarjit Singh Dhillon and Ajinder Kaur, appealed from a lower court's grant of partial summary judgment to Michael Dahlem, who owns neighboring property and challenged the contract zone agreement. Dahlem cross-appealed from the court's dismissal of his Rule 80B appeal and denial of his motion to reconsider that dismissal, and from the court's denial of summary judgment on two counts in his complaint.The lower court had granted summary judgment to Dahlem on several counts, declaring that the 2017 agreement became null and void in 2019 and thereafter could not be amended, was invalid and unlawful for noncompliance with the City’s contract zoning ordinance, and was inconsistent with Maine’s Mandatory Shoreland Zoning statute and therefore preempted and invalid. The court denied summary judgment to all parties on the count of whether the 2021 agreement was compatible with the City’s comprehensive plan.The Maine Supreme Judicial Court affirmed the lower court's decision in all respects and dismissed Dahlem’s cross-appeal as moot. The court held that Dahlem properly challenged the 2021 agreement by asserting claims for declaratory relief, that the 2017 agreement became null and void on November 20, 2019, and could not thereafter be amended, that the 2021 agreement was invalid and unlawful under the City’s contract zoning ordinance, and that the 2021 agreement was preempted by the Mandatory Shoreland Zoning provisions. View "Dahlem v. City of Saco" on Justia Law

Michael G. Saucier was convicted by a jury in the trial court (Aroostook County, Nelson, J.) for one count of gross sexual assault (Class A), one count of unlawful sexual contact (Class B), and one count of unlawful sexual contact (Class C). The charges stemmed from incidents that occurred when Saucier was the stepfather of the victim. The key issue was whether there was sufficient evidence to prove the victim's age at the time of the offenses, which was a crucial element for each of the charges.The trial court denied Saucier's motion for a judgment of acquittal on all counts, except for one count of unlawful sexual contact (Class B) due to insufficient evidence to prove that the victim was under twelve years old when the offense occurred. The jury found Saucier guilty on the remaining three counts. Saucier was sentenced to twenty-two years for the Class A offense, with nine years for the Class B offense and five years for the Class C offense, all to be served concurrently.On appeal, the Maine Supreme Judicial Court found that the evidence regarding the victim's age was sufficient to sustain a conviction on the Class C offense but not on the Class A and B offenses. The court noted that the State failed to provide evidence to identify the victim's date of birth or her age during the relevant time period. The court concluded that while the jury could reasonably infer that the victim was under fourteen during her time in Exeter, no such inference could be made that she was under the age of twelve. Consequently, the court vacated the convictions on the Class A and B offenses, affirmed the conviction on the Class C offense, and remanded the case for resentencing on the Class C offense. View "State v. Saucier" on Justia Law